United States District Court, E.D. California
ZENIA K. GILG, San Francisco CA Attorney for Defendant KEVIN DENNIS GOLDEN.
JILL M. THOMAS, Assistant U.S. Attorney, U.S. Attorney's Office.
STIPULATION AND [PROPOSED] ORDER TO MODIFY THE CONDITIONS OF PRETRIAL RELEASE
GARLAND E. BURRELL, Jr., District Judge.
THE PARTIES HEREBY STIPULATE AND AGREE that the conditions of pretrial release imposed on defendant, Kevin Golden, may be modified to allowed him to travel for work purposes only to the Central and Southern Districts of California and Hawaii without a court order, but with notification to pretrial.
As indicated in the letter written by Mr. Golden's employer, John Hinmon, he is requesting that Mr. Golden be permitted to travel within the State of California and Hawaii, as these are the locations at which the company TABCO performs services on industrial and commercial buildings in the areas of technical and sensitive environments. Mr. Hinmon writes, "Mr. Golden's extensive knowledge of mechanical systems and engineering background has proven a great value to TABCO, as he is the only employee who can perform thermodynamic engineering and finite element analysis on site. In addition to his unique training in thermodynamics, Mr. Golden's commissioning and troubleshooting skills are beyond superb." (See, Attachment.) Mr. Hinmon further indicates that due to the nature of the business the company is called upon to service a site without sufficient notice to allow time to obtain a Court order permitting travel outside the Northern and Eastern Districts of California.
As Mr. Hinmon is asking that Mr. Golden be given more flexibility in his ability to travel, it is the request of the parties to modify the conditions of pretrial release which would permit Mr. Golden to travel throughout the State of California and Hawaii for work purposes, provided he give notice to pretrial services when he is called upon by TABCO to leave the Northern or ...